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SAMPLE ESSAY (MLA Style) 

What Limits to Freedom? 

Freedom of Expression and the Brooklyn Museum’s 

“Sensation” Exhibit 

by Melissa Davis 

Prof. K.D. Smith 

Humanities 205 

16 May 2009 

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What Limits to Freedom? 

Freedom of Expression and the Brooklyn Museum’s 

“Sensation” Exhibit 

For over a century public galleries in Western democracies have 

been forums not only for displaying works by “old Masters” but also 

for presenting art that is new, as well as ideas that are sometimes 

radical and controversial. In the United States that tradition has 

been under wide attack in the past generation. Various political and 

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of all religious leaders have criticized exhibits of works of art that they claim 

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indented offend against notions of public decency, and have crusaded against 

providing public funding for the creation or display of such works. 

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Melissa Davis 

Professor Smith 

Humanities 205 

16 May 2009 

The largest such controversy of the past generation was sparked by the 

display of a painting entitled “The Holy Virgin Mary,” by the British 

artist Chris Ofili at the Brooklyn Museum in 1999. Though the 

image appears inoffensive at a distance, the artist has affixed to the 

painting cutouts of body parts from magazines, and has incorpo- 

rated clumps of elephant dung into the piece, both below the main 

body of the work as if supporting it and as part of the collage. The 

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Davis 1 


Sample Essay | 87 

resulting uproar led both to a widely publicized court case and to an 

ongoing campaign to support “decency” in artistic expression. Should 

such art be banned? Should it be exhibited at public expense? In the 

course of the Ofili controversy cultural conservatives raised legitimate 

concerns about the obligation of any society to provide funding for 

activities of which it disapproves. This essay will argue, however, that 

the greater concern is in the other direction; a free society must con- 

tinue to provide opportunities for the free expression both of artistic 

vision and of controversial thought. 

The Ofili piece was part of a much-hyped exhibit entitled 

“Sensation: Young British Artists from the Saatchi Collection.” As 

the title indicated, the show was made up entirely of works from one 

collection, that of the wealthy British advertising executive Charles 

Saatchi. 1 The exhibition had been shown first at the Royal Academy 

of Arts in London and then at a major gallery in Berlin. (In London 

what sparked controversy was not Ofili’s work but rather a realistic 

painting by Marcus Harvey of child-murderer Myra Hindley that 

incorporated hundreds of children’s handprints into the image.) 

Bringing the show to Brooklyn cost one million dollars—a cost 

Davis 2 

covered in part by Christie’s, a London auctioneer—and from the 

outset it could be argued that the museum was courting controversy. 

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It claimed in its advertising that the exhibition “may cause shock, 

vomiting, confusion, panic, euphoria, and anxiety. If you suffer from 

high blood pressure, a nervous disorder, or palpitations, you should 

consult your doctor” (qtd. in Barry and Vogel). 

No doubt that warning was tongue-in-cheek, but there was 

nothing ironic about the angry reactions provoked by the show in 

general and directed toward the Ofili piece in particular. On one side 

art critics and civil libertarians were full of praise; in The New York 

Times the work was praised as “colorful and glowing” (Kimmelman). 

On the other side John Cardinal O’Connor called it “an attack on 

religion,” and the president of the Catholic League for Religious 

and Civil Rights called on citizens to picket the exhibition (qtd. in 

Vogel). The United States Senate and the House of Representatives 

both passed resolutions condemning the exhibit. Even more vehement 

was the response of New York Mayor Rudy Giuliani (later to become 

famous for his leadership in the wake of the September 11, 2001 

terrorist attacks, and in 2008 to run for president); he declared himself 

“offended” and the work itself “sick” and “disgusting” (qtd. in Barry 

and Vogel). He ordered that ongoing city funding of the museum be 

withheld until the offensive work was removed, and launched eviction 

proceedings against the museum. Other conservative politicians— 

Davis 3 



then-Texas Governor George W. Bush prominent among them—spoke 

out in support of Giuliani’s stand (“Bush Backs Giuliani”). 

What was the substance of Mayor Giuliani’s case? Here is how he 

explained his stance in two statements to the press: 

You don’t have a right to a government subsidy to desecrate 

someone else’s religion. And therefore we will do everything 

that we can to remove funding from the [museum] until 

the director comes to his senses and realizes that if you are a 

government subsidized enterprise then you can’t do things 

that desecrate the most personal and deeply held views of 

people in society. (qtd. in Brooklyn Institute of Arts and 

Sciences v. City of New York 7) 

“If somebody wants to do that privately and pay for that 

privately ... that’s what the First Amendment is all about,” 

he said. “You can be offended by it and upset by it, and you 

don’t have to go see it, if somebody else is paying for it. But 

to have the government subsidize something like that is 

outrageous.” (qtd. in Vogel) 

But is it outrageous? Let us examine the implications of Giuliani’s 

argument. According to him, government should never provide 

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funding for activities that some people may find deeply offensive. But 

governments have long funded much artistic and intellectual activity 

in advance on the grounds that such activity in general represents a 

social good, without knowing precisely what sort of artistic work will 

be created or exhibited, what results academic research may come up 

with, and so on. If such funding were to be always contingent on no 

one ever being deeply offended by the results of the artistic or intellec- 

tual activity, the effect would be to severely damage freedom of speech 

and expression. (Here it is important to note that the actions Giuliani 

took were retroactive; the annual funding for the museum had not 

been provided with strings attached.) 2 

Social conservatives are often characterized as favoring censor- 

ship of any material they find offensive; to be fair, that is clearly not 

the position Giuliani takes here. Nor is the issue whether or not the 

material is offensive; Hillary Clinton, for example, agreed that works 

such as that by Ofili were “objectionable” and “offensive” (qtd. in 

Davis 5 

Nagourney), while opposing any punitive actions against the museum. 

Rather, the issue at stake is under what conditions government has an 

obligation to fund controversial artistic or intellectual activity. To that 

question at least one short answer should be plain: an obligation exists 

where a prior commitment has been made. As Judge Nina Gershon 


put it in her eventual ruling on the case, 


the issue is ... whether the museum, having been allocated 

a general operating subsidy, can now be penalized with 

the loss of that subsidy, and ejectment from a City-owned 

building, because of the perceived viewpoint of the works 

in that exhibit. The answer to that question is no. (Brook- 

lyn Institute v. City of New York 17) 

Where such a commitment has been made it can only be fairly broken 

if the activity has in some way contravened previously agreed-on 

guidelines or if it has broken the law. If, for example, a work of art or 

of literature is thought to violate laws against obscenity, laws concern- 

ing hate crimes, laws concerning libel and slander—or, indeed, laws 

concerning cruelty to animals, as in the cases of certain “works of art” 

in recent years 3 —then legal recourse is available. But not even the 

Davis 6 

most vociferous of the opponents of the “Sensation” exhibit suggested 

that Ofili, the curators, or anyone else had broken the law. Moreover, 

the ongoing funding for the Museum had never been made contin- 

gent on the institution’s exhibits never offending anyone. There were 

therefore no just grounds for taking punitive action as Giuliani did. 

But how much further than this should the obligation of govern- 

ment to fund controversial artistic or intellectual activity extend? Do 


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governments have a general or unrestricted obligation to support and 

to fund such activity? The tradition of government support for artistic 

and intellectual activity in Western democracies has for many genera- 

tions been one in which support was provided at “arm’s length” from 

the political process; if judgments based on the merit of individual 

works need be made, they are typically made by bodies independ- 

ent of government. That approach has stemmed from a number of 

sensible general principles. One such principle has been a recognition 

of the inherent value of intellectual and artistic activity. Another has 

been a recognition that such activity will sometimes be challenging, 

disturbing, even offensive or disgusting. 4 And a third has been that 

if politicians are involved in judging individual artistic or intellectual 

works, the judgments will tend to be made more on political and 

religious grounds than on intellectual and esthetic ones. We value a 

society in which a wide range of free expression is supported, and we 

have come to expect that governments will provide a good deal of that 

support. 

Davis 7 

Despite the general support for these principles that exists in our 

society, we should not assume an unlimited obligation on the part of 

government. In particular, liberals and civil libertarians are unwise if 

they suggest that the obligation of the government to support artistic 



or intellectual endeavor is always a strong and compelling one, or 

that any failure of a government to provide financial support for such 

endeavor somehow constitutes censorship. 5 There is no clear agree- 

ment as to what constitutes art; it follows that there can be no legal 

or moral obligation to fund everything that may be classified as art. 

And to decide in advance not to subsidize an activity is not the same 

as censoring that activity; civil libertarians do not advance their case 

by equating the two. Indeed, as philosopher Peter Levine has pointed 

out, attempts to remove all restrictions on government support can 

easily backfire, since the law 

cannot compel governments to subsidize art in the first 

place. When the Supreme Court ruled in 1998 that 

individual artists may not be denied federal grants because 

of the content of their work, Congress simply cancelled all 

support for individual artists. (2) 

If it is a great mistake for the artistic and intellectual com- 

Davis 8 

munities to press too hard for unrestricted government support, it is 

perhaps an even greater mistake for cultural conservatives to seek to 

restrict government support to work that conforms to their definition 

of “decency.” The moral obligation of government to support a broad 

range of artistic and intellectual expression may be a relatively weak 

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one, but if we cast it aside we are choosing to narrow ourselves, to 

discourage rather than encourage the sorts of challenge from new ideas 

and new artistic expressions that continually replenish the red blood 

cells of democratic society. In approaching such questions we should 

ask ourselves what really constitutes freedom of thought, speech, and 

expression. One defining pillar is legal: constitutional guarantees of 

freedom and the case law that has helped to define them. 6 But is that 

all there is to it? A moment’s reflection should make it clear that a 

great deal else is involved. Regardless of what is allowed or prohibited, 

if there exists a scarcity of art galleries—or of book publishers, or 

of academic journals, or of newspapers, or of radio and television 

stations—that are willing to put forward original and controversial 

works of art, or works of scholarly research, or political treatises, then 

freedom of speech and expression is in practice severely limited. 7 And 

economic reality dictates that a number of valued activities, including 

academic research as well as many of the arts, would be severely cur- 

tailed without some degree of public funding. If we choose as a society 

not to fund such activities we will inevitably be erecting real barriers 

against freedom of speech and expression, even if we have passed no 

laws restricting such freedoms. That is the reality at the heart of the 

“Sensation” controversy. 

Davis 9 



It is interesting that in the midst of the controversy Ofili’s work 

itself became oddly invisible, lost in the clamor of arguments from 

principle on both sides of the debate. Photographic representations 

of “Holy Virgin Mary” are widely available on the Web, 8 and viewers 

coming to these after sampling the heat of the arguments surrounding 

the piece are likely to be surprised by how calm and pleasant an image 

is presented to them. Ofili himself was the recipient of the prestigious 

Turner Prize in 1998 and has been widely recognized as one of the 

most important of his generation of British artists. Fairly typical are 

the comments of a writer in Art in America, one of the most authori- 

tative journals of contemporary art criticism: “his paintings are a 

joy to behold.... His technique, as it becomes ever richer and more 

complex, is developing an emotional range to match its decora- 

tive facility” (MacRitchie). The painter, who was born in Britain to 

parents of Nigerian background, was raised—and still remains—a 

church-going Catholic. (Clearly critics’ claims that “The Holy Virgin 

Mary” is offensive to Catholics cannot be true of all Catholics!) Ofili 

has spoken interestingly of how he draws connections between the 

subjects of his work and the materials he uses, including shiny varnish 

to make it seem that the subject of a painting is “in some ways more 

imagined than real” (qtd. in Vogel), and, of course, the notorious 

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balls of elephant dung that adorn the work and on which it rests. 9 

Significantly, Ofili has incorporated dung into many of his works, 

including those portraying slaves and other African subjects. As 

Arthur C. Danto has pointed out, “since it is unlikely that as a black 

Anglo-African Ofili would have used dung to besmirch the slaves [in 

the picture “Afrobluff”], there is no reason to suppose he was bent on 

besmirching the Holy Virgin through its presence there either” (2). 

From one angle, Ofili clearly sees the use of dung as a way of connect- 

ing his paintings to his African heritage and of giving the paintings “a 

feeling that they’ve come from the earth” (qtd. in Vogel). But he also 

aims to create a tension between the superficially appealing nature of 

his images and the inherent unpleasantness of some of the materials he 

has used to create them: 

“The paintings themselves are very delicate abstractions, and 

I wanted to bring their beauty and decorativeness together 

with the ugliness of shit 10 and make them exist in a twilight 

zone—you know they’re together, but you can’t really ever 

feel comfortable about it.” (qtd. in Sensation) 

One does not need to endorse all of Ofili’s theorizing about what he 

does, or agree fully with the favorable assessments of the critics in 

Davis 11 

order to conclude that it would be unreasonable not to classify his 



work as art. Even the narrowest and most conservative definitions 

of art allow the term to be applied to work that many people find 

pleasing to the eye and that many agree demonstrates creative skill. 

Ofili’s work unquestionably fulfills those criteria. More than that, 

there is evidently a good deal of subtlety and nuance to both the 

work and the ideas of this painter, far more than the polarized debate 

swirling around the painting might suggest. Even if some find this art 

offensive, it is hard not to think that on its merits Ofili’s work deserves 

to be widely exhibited. 

In a narrow sense the controversy of the Ofili work and the Sen- 

sation exhibit ended with a clear victory for the Brooklyn Museum. 

Federal Judge Nina Gershon ruled that in these circumstances the 

City of New York’s attempt to shut down the exhibit constituted a vio- 

lation of the First Amendment—the Constitutional guarantee of free- 

dom of expression—and in March of 2000 the City and the museum 

reached an agreement under the terms of which all further lawsuits 

were dropped and the City agreed to contribute 5.8 million dollars 

towards a museum restoration project. (The museum re-opened in 

2004 after the completion of restorations.) But in a wider sense the 

outcome is far less certain. In 2001 Mayor Giuliani attempted to 

Davis 12 

develop “decency standards” intended to restrict these sorts of works 


13


from being shown in future in publicly funded exhibitions, and such 

initiatives received strong support from the administration of George 

W. Bush. Among certain commentators the crusade against Ofili has 

continued unabated long after the exhibit itself had ended. Phyllis 

Schlafly is one such crusader (1999); Tammy Bruce is another. In 

her best-selling book The Death of Right and Wrong, for example, 

Bruce uses the case as an example in urging us to “make no mistake: 

the degrading of symbols important to Christianity is ... propaganda 

meant to change your view of Christianity as a whole” (52). Given the 

persistence of attacks of this sort, major museums and galleries must 

have real courage to mount exhibitions of work that they consider 

likely to be controversial. Tellingly, the “Sensation” exhibit was never 

seen after it closed in Brooklyn; the National Gallery of Australia 

Davis 13 

canceled its plans to show the exhibit, and a Tokyo museum that had 

expressed interest in exhibiting it thereafter did not in the end make 

any commitment (Rosenbaum). More recently, the San Francisco Art 

Institute closed Adel Abdessemed’s controversial “Don’t Trust Me” 

show after only a few days “for safety reasons” (DeBare B1) in the face 

of protests by animals’ rights groups and some artists, though there 

had been no suggestion that any law had been broken, and though 

condemnation of the show had been far from universal. 11 



Legal victories in defense of freedom of expression, then, will 

never in themselves suffice. The preservation of a truly open society 

requires, on the part of those who wish to allow and to encourage 

freedom of expression, a moral determination that is at least as strong 

as the moral determination of those who wish to roll back its frontiers. 

Much as constitutional guarantees of freedom of expression are 

important, even more so is whether we wish as a society to narrow the 

range of what citizens may readily see or hear, or instead to encour- 

age the wide dissemination of information, opinion, and artistic 

expression—even opinions and artistic expressions that some may 

find offensive. In the years since the September 11, 2001 attack, it is 

understandable that many both within the United States and around 

the world have been prepared to accept some new restrictions on 

freedom. But whatever justification there may be for such restrictions 

does not extend to the sphere of intellectual and artistic activity. If we 

wish to retain a robustly democratic society we should continue to 

choose the path of openness. 

Davis 14 

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Notes 

1. Saatchi contributed $100,000 to mounting the show, the 

economics of which became another subject for controversy when it 

was shown in Brooklyn. As well as complain about the content of the 

works in the exhibit, Mayor Rudy Giuliani and others suggested that 

the show had been intended in large part to raise the value of works 

in the Saatchi collection, and on those grounds, too, argued that the 

exhibit should not be receiving a subsidy from taxpayers. 

2. Because its content was recognized as controversial, city 

officials had been provided in advance of the “Sensation” show with 

photographs and full descriptions of all pieces to be included in the 

exhibit, including the information that Ofili’s works incorporated 

elephant dung into the images they portrayed. The mayor insisted 

that he personally had not been alerted to the content of the show 

beforehand, however. 

3. Animal rights activists have protested against works by the 

renowned British artist Damien Hirst, which present, among other 

things, a sectioned cow and a bisected pig in formaldehyde cases. 

Davis 15 

(Several such works by Hirst were included in the “Sensation” show.) 

In Toronto, art student Jesse Power and two friends pleaded guilty in 



2001 to charges of animal cruelty and public mischief after making 

what they called an art video recording their torturing and killing a 

cat; the case again aroused controversy in 2004 following the release of 

a documentary film about the incident, Casuistry: The Art of Killing a 

Cat, directed by Noah Cowan and Piers Handling. See also the articles 

by Christie Blatchford and by Gayle MacDonald, and Note 11 below 

on the 2008 “Don’t Trust Me” exhibition in San Francisco. 

4. There are many defenses of the principle that an open society must 

make a place even for controversial or disgusting material. The case for the 

other side is put by John Kekes in A Case for Conservatism; he argues for 

what he terms “the moral importance of disgust” (100–109). 

5. To be fair, although some individuals make assertions as 

extreme as this one, responsible civil liberties organizations such as the 

ACLU stop short of any such all-embracing claim. 

6. The First Amendment to the American Constitution specifies 

that Congress “shall make no law ... abridging the freedom of speech, 

or of the press; or the right of the people to assemble....” In American 

legal practice it has long been established that “freedom of speech” 

should also cover other forms of expression—such as artistic works. 

Other, more recent constitutions tend to make such protections 

explicit; the Charter of Rights and Freedoms that forms a central 

Davis 16 



part of the Canadian Constitution, for example, protects “freedom 

of thought, belief, opinion, and expression, including freedom of the 

press and other media of communication.” 

7. A good example of how such freedoms may be constrained 

is the March 2003 case in which Natalie Maines of the Dixie Chicks 

criticized George W. Bush—and promptly found that two media con- 

glomerates controlling over 1,300 radio stations refused to play Dixie 

Chicks music. That case is discussed by Robert B. Reich in Reason: 

Why Liberals Will Win the Battle for America. 

8. Among the many Web addresses at which photographs of the 

work may be found are www.artsjournal.com/issues/Brooklyn.htm 

and www.postmedia.net/999/ofili.htm and www.geocities.com/south- 

ernhelle/sensation3.html. 

9. Many who have attacked the piece have chosen to describe the 

dung as being “smeared on a Christian icon” (Bruce 39, my italics), 

which is substantially to misrepresent the nature of the work. 

10. It is interesting to contemplate the impact diction may have 

on arguments such as this; it is difficult not to respond slightly differ- 

ently depending on whether the material is referred to using the noun 

Ofili uses here or referred to less provocatively as “dung.” 

Davis 17 

11. The show included video clips of the killing of animals in 



Davis 18 

rural Mexico. The artist had evidently not arranged for the killings; he 

was merely recording local practice. For more on this and other recent 

controversies, see the articles by Kenneth Baker and Phoebe Hoban. 



works cited are 

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each 

entry 

begins 

at left 

margin; 

subsequent 

lines 

are in- 

dented 

Works Cited 

Baker, Kenneth. “Show’s Cancellation a Rare Case of Artists Advocating Cen- 

sorship.” San Francisco Chronicle 1 Apr. 2008: E1. Print. 

Barry, Dan, and Carol Vogel. “Giuliani Vows to Cut Subsidy over Art He Calls 

Offensive.” New York Times 23 Sept. 1999: n. pag. Web. 2 May 2009. 

Blatchford, Christie. “Face to Face with Cruelty.” Globe and Mail 4 Sept. 2004: 

A13. Print. 

Brooklyn Institute of Arts and Sciences v. City of New York 99CV 6071. New 

York Law Journal 1 Nov. 1999: n. pag. Web. 1 May 2009. 

Bruce, Tammy. The Death of Right and Wrong. New York: Three Rivers, 2003. 

Print. 

“Bush Backs Giuliani on Museum Flap.” Associated Press 4 Oct. 1999: n. pag. 

Washingtonpost.com. Web. 3 May 2009. 

Danto, Arthur C. “‘Sensation’ in Brooklyn.” The Nation 1 Nov. 1999: n. pag. 

Web. 1 May 2009. 

DeBare, Ilana. “Art Institute Halts Exhibition Showing Killing of Animals.” San 

Francisco Chronicle 30 Mar. 2008: B1. Print. 

Hoban, Phoebe. “How Far Is Too Far?” ArtNews Summer 2008: 145-49. Print. 

Kekes, John. A Case for Conservatism. Ithaca, New York: Cornell UP, 1988. 

Print. 

Davis 19 



Kimmelman, Michael. “A Madonna’s Many Meanings in the Art 

Davis 20 

World.” New York Times 5 Oct. 1999: n. pag. Web. 2 May 2009. 

Levine, Peter. “Lessons from the Brooklyn Museum Controversy.” 

Philosophy and Public Policy Quarterly 20.2/3 (2000): n. pag. 

Web. 3 May 2009. 

MacDonald, Gayle. “TIFF Contacts Police over Death Threat: Caller 

Threatens Programmer over Cat-Killer Documentary.” Globe and 

Mail 1 Sept. 2004: R1. Print. 

MacRitchie, Lynn. “Ofili’s Glittering Icons.” Art in America Jan. 2000: 

n. pag. Find Articles at BNET. BNET. Web. 1 May 2009. 

Nagourney, Adam. “First Lady Assails Mayor over Threat to 

Museum.” New York Times 28 Sept. 1999. n. pag. Web. 1 May 

2009. 

Reich, Robert B. Reason: Why Liberals Will Win the Battle for America. 

New York: Knopf, 2004. Print. 

Rosenbaum, Lee. “The Battle of Brooklyn Ends, the Controversy 

Continues.” Art in America June 2000: n. pag. Find Articles at 

BNET. BNET, n.d.Web. 4 May 2009. 

Schlafly, Phyllis. “Time to Abolish Federally Financed ‘Hate Art.’” 

Eagle Forum. Eagle Forum, 13 Oct. 1999. Web. 2 May 2009. 

double 

spacing 

used 

throughout 

italics used 

for titles 

of books, 

journals, 

magazines, 

etc. 



Sensation: Young British Artists from the Saatchi Collection. Guide- 

book. Geocities.com. Yahoo, n.d. Web. 2 May 2009. 

“Turner Prize: Twenty Years.” Tate Gallery Online. Tate Gallery, 

2003. Web. 1 May 2009. 

Vogel, Carol. “Chris Ofili: British Artist Holds Fast to His 

Inspiration.” New York Times 28 Sept. 1999: n. pag. Web. 

2 May 2009. 

Davis 21

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